Domingo v Robles (453 SCRA 812)

Facts:
The petitioner Norma Domingo and her husband, Valentino Domingo, own a lot in
Concepcion, Marikina. On this lot, Norma B. Domingo discontinued the construction
of the house allegedly for failure of her husband to send the necessary financial
support. So, she decided to dispose the property.
A friend, Flor Bacani, volunteered to act as agent in selling the lot. Domingo
delivered their owner’s copy of Transfer Certificate of Title. The title was then said to
have been lost. In the petition for its reconstitution, Domingo gave Bacani all her
receipts of payment for real estate taxes, Bacani then asked her to sign what she
recalled a record of exhibits. Bacani did not show up anymore.
Domingo visited the lot and was surprised to see Robles starting to build a house in
the subject lot. A verification with the Register of Deeds revealed that the
reconstituted Transfer Certificate of Title had already been cancelled with the
Registration of the Deed of Absolute Sale signed by Norma Domingo and her
husband, as sellers, and Yolanda Robles, as buyer.
The petitioner claimed that she did not met any of the respondents nor having signed
any sale over the property in favor anybody, assumed that the Deed of Absolute Sale
is a forgery and therefore, could not validly transfer ownership. Robles responded
alleging to be buyers in good faith and value. Sometime later, Robles contracted to
sell the lot in issue, payment was stopped because of the letter Robles received that
Domingo intends to sue her. The Regional Trial Court dismissed the complaint.
The CA held that respondents were purchasers in good faith and for value. The sale
was admittedly made through petitioners agent, Bacani brought with him the original
of the owners duplicate Certificate of Title of the property and some receipts.
Petitioner was not able to present any evidence to prove that respondents had prior
knowledge of any other persons right to or interest over the property in question.
Issue:
Whether or not the petitioner is entitled to her claims.
Whether or not there was an acquisition of a valid title.
Ruling:
It is a well-established principle that factual findings of the trial court, when affirmed
by the Court of Appeals, are binding on this Court . The findings of the courts a quo
are amply supported by the evidence on record.
A notarized instrument enjoys a prima facie presumption of authenticity and due
execution. Clear and convincing evidence must be presented to overcome such legal
presumption. Forgery cannot be presumed; hence, it was incumbent upon petitioner to
prove it. The petition is denied and the assailed decision affirmed.